The following comments have been submitted:
Comment #1Page Number: 3 & 4Paragraph / Figure / Table / Note: A-1.3.2 & A-1.3.3Comment Intent: ObjectionComment Type: TechnicalComment: The proposal is replacing the requirement for an air barrier on all six sides of insulation with a requirement to use "durable materials". However, there is no definition of "durable materials". This change leaves the standard open for a very wide range of interpretation and a watering down of good building science application. The exceptions listed below this change in these sections all deal with air barrier requirements, but if the requirement is removed, then the exceptions no longer tie to the requirement and only add confusion to the standard. There is no justification given for making this change. This change should be abandoned. Proposed Change: Insulation shall be enclosed on all six sides with an air barrier with durable materials.
The proposal is replacing the requirement for an air barrier on all six sides of insulation with a requirement to use "durable materials". However, there is no definition of "durable materials". This change leaves the standard open for a very wide range of interpretation and a watering down of good building science application. The exceptions listed below this change in these sections all deal with air barrier requirements, but if the requirement is removed, then the exceptions no longer tie to the requirement and only add confusion to the standard. There is no justification given for making this change. This change should be abandoned.
Insulation shall be enclosed on all six sides with an air barrier with durable materials.
Comment #2Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: Why does it need to be at Level III IR camera certification? I believe Level I is sufficient to determine the insulation is in the cavity and eligible for insulation grading of II or III Proposed Change: Change it to "Level I ASNT NDT"
Why does it need to be at Level III IR camera certification? I believe Level I is sufficient to determine the insulation is in the cavity and eligible for insulation grading of II or III
Change it to "Level I ASNT NDT"
Comment #3Page Number: 2Paragraph / Figure / Table / Note: A-1.2Comment Intent: ObjectionComment Type: TechnicalComment: This detail needs further clarification. From a perspective of maintaining the the R-value (i.e., U-value) of fiberglass batts or other fiberous insulation it needs an air-barrier on the “interior” side of the insulation so it achieves encapsulation on all 6-sides. An air-barrier on the exterior side will be sufficient to stop air-leakage to the outside but fiberous insulation will lose R-value via convection if it is not fully encapsulated. Just as we don't require an air-barrier on top of fiberous insulation because it has a "high" R-value, I would at least say RESNET needs to require a minimum of R-30 insulation, when it is fiberous, before an air-barrier isn't required on on all 6 sides, at least in climate zones 1 thru 6. Proposed Change: Change it to "Rim-joists must have an air barrier on the inside (6-sided encapsulaiton) when fiberous insulaiton is installed at any R-value below R-30".
This detail needs further clarification. From a perspective of maintaining the the R-value (i.e., U-value) of fiberglass batts or other fiberous insulation it needs an air-barrier on the “interior” side of the insulation so it achieves encapsulation on all 6-sides. An air-barrier on the exterior side will be sufficient to stop air-leakage to the outside but fiberous insulation will lose R-value via convection if it is not fully encapsulated. Just as we don't require an air-barrier on top of fiberous insulation because it has a "high" R-value, I would at least say RESNET needs to require a minimum of R-30 insulation, when it is fiberous, before an air-barrier isn't required on on all 6 sides, at least in climate zones 1 thru 6.
Change it to "Rim-joists must have an air barrier on the inside (6-sided encapsulaiton) when fiberous insulaiton is installed at any R-value below R-30".